Compliance

Corporate Management Principles

Declaration of Principles on Human Rights and Environmental Due Diligence
- ebm‑papst code of conduct -

An important part of our corporate culture is that our actions are guided not only by legal requirements, but also by a commitment to ethical standards. We are respectful towards people and the environment and cherish them. In this context, compliance with human rights and environmental due diligence obligations is a top priority for ebm‑papst.

ebm-papst is a special company. This mainly comes down to our fundamental values that we have been working with for over 60 years. 

Harald Klaiber
Chief Financial Officer (CFO) ebm-papst Group

The ebm‑papst Code of Conduct:
Our principles for acting responsibly and legitimately

This can be supported and expanded by rules and training specific to the area or country. Our managers have a particular responsibility. They must set an example by following the rules and values of ebm-papst described in this code of conduct. They are the first point of contact if any employees have questions about the correct way to behave. They are responsible for ensuring compliance with the code of conduct.

The relevant line manager, the managing director of the site and subsidiaries or the commercial Group management will answer any questions on how to behave on a case-by-case basis.

All ebm-papst Group employees must follow our code of conduct.

Violations will not be tolerated and may result job loss or criminal proceedings.

Overriding Principle

We think it is only fair to act in accordance with the laws and we believe in honesty. We always abide by the laws of the countries in which we work. Illegal action is not an option and not in the interests of our company, as it is unethical, seriously damaging to our reputation and can lead to prosecution, claims for damages and loss of business.

Any employees breaching the law must be aware that they themselves will be at risk of legal consequences, such as e. g. prosecution or consequences under labour law. Acting in conformity with the law is in the best interests of each employee.

All employees are required to familiarize themselves with and abide by the regulations applicable to their area of responsibility. In cases of doubt, the council of a senior employee should be sought.

Responsible Business Alliance® (RBA®)

We have committed to comply with the Responsible Business Alliance® (RBA®) Code of Conduct, whose content enhances our own Code of Conduct.

The RBA® Code of Conduct is a key component of our supply chain and we expect all of our business partners to give their commitment to uphold its values. In addition, the RBA® Code of Conduct is an integral part of our Supplier Code of Conduct, which is applied in the relationship with our suppliers and also represents a significant part of our supply chain.

The core concerns of the RBA® Code of Conduct are safe working conditions, treating employees with respect and dignity, and environmentally compatible, ethically tenable business processes.

Social Responsibility and Sustainability

ebm‑papst is committed to fulfilling its social responsibilities and making a positive impact in the community. Beyond our compliance with the legal stipulations, we make a voluntary contribution to the sustainable development of the ebm‑papst Group and our surroundings.

Besides efficiency and enthusiasm, humanity is at the centre of our actions. We are never inconsiderate in our drive for success. We understand ourselves to be open, reliable and loyal to our customers and employees. We behave with integrity. As a company, we know that we also have an obligation to society. We create the space that each and every one of us requires to develop – and we reward performance.

In everything we do, we also consider the long-term effects. Resource preservation, energy efficiency, environmental protection and employee development safeguard the future for us. With our sincere, sustainable behaviour, we intend to set an international example and do our part to make our world’s division of labour fairer.

Human rights

Human rights are universal, inalienable and indivisible rights to which everyone is equally entitled. Respect for these fundamental rights is an integral part of our corporate culture.

We are committed to respecting internationally recognized human rights throughout our business operations and expect our business partners in the supply chain to also commit to these values and implement them in their value chains.

We conduct appropriate due diligence checks including supply chain due diligence in particular when selecting suppliers and in our dealings with existing suppliers. We demand and promote fair working conditions. This means, that we screen our own operations and supply chain for any potential environmental and human rights risks in order to prevent or mitigate any violation or risk.

We do not tolerate conduct that contributes to or supports human rights abuses. We take adequate corrective action in the event of human rights violations.

Bribery, Corruption, Gifts, Gratuities

Bribery and corruption are illegal and unethical. Both constitute considerable risks for our employees and our company. Bribery and corruption represent a threat to the existence of any company. They are therefore neither an option nor an acceptable practice – even if this means a loss of revenue.

We neither offer impermissible benefits to our trading partners nor do we accept any such benefits ourselves.

We consider corrupt behaviour as being constituted by, e.g. facilitation payments, kickbacks and financial incentives as well as by having recourse to third parties/agents.

We exercise restraint with regard to both accepting and offering gifts and other gratuities (including invitations to dine or other activities for example). Any such action must never take a form which exceeds normal business hospitality, manners and courtesy.

Taxes and subsidies

The tax laws of every country are binding for us and must therefore be strictly observed. Every employee must be aware that tax offenses are liable to prosecution. This applies equally to both the company and the individual employee. On account of regular and thorough inspections by the tax authorities, there is a high risk of tax offences being discovered.

Suspicious circumstances very quickly lead to criminal investigations. If customers and suppliers are involved, cross-checks will be made with their tax authorities and vice versa.

The legal situation with regard to taxation and subsidies is often very difficult to assess. In cases of doubt, a senior employee should be consulted and/or clarification must be requested from the Managing Director Finance & Administration.

Principles of Fair Competition

Competition can only work if it is free and fair. Agreeing with competitors on coordinated market action is detrimental to competition. That is why we do not come to any arrangements with competitors regarding our business practices. We abide by the laws on the protection of competition. We specifically prohibit any agreements on prices and terms, the apportionment of markets and regions, the allotment of customers and the coordination of quotation, development and production strategies. Any exchanging of information with competitors which could form the basis for coordinated behaviour (in particular with regard to prices, costs, margins, terms, customers, quotations, product developments and manufacturing capacity) cannot be tolerated and is strictly forbidden.

Any violation of these bans is rigorously pursued by the cartel authority and can lead to sanctions which may endanger the existence of our company.

International Trade

International trade is of vital benefit to ebm‑papst. So, supporting it and abiding by the pertinent rules is very much in our own interest. Consequently, we observe the existing import and export regulations, obtain the necessary permits and pay the applicable customs duties and taxes.

The authorities regularly check compliance with these regulations. Severe sanctions may be imposed in the event of any violation.

We protect third party ownership rights

Property belonging to our or other companies is handled, treated and used carefully and responsibly. This also means considering the integrity of our trading partners.

Intellectual property

We respect third party intellectual property. Being a technology supplier investing a lot of effort in research and development, the protection of inventions and expertise is vitally important to ebmpapst. That is why we treat business secrets with the utmost care. It must be ensured that confidential information is not passed on to unauthorized third parties.

The same also applies to confidential information we receive from our trading partners. If special circumstances (e.g. customers’ sensitive development projects or company take-overs) require strict confidentiality, this must also be maintained, even with and towards colleagues.

Data Privacy

We only use the personal data of our employees and business partners for the express purposes for which they have been provided and always treat such data confidentially. ebm‑papst strictly maintains all applicable laws on personal data privacy.

Business Records

Both internal and external reports must be accurate and complete to provide the recipient with the appropriate information. We concentrate on the representation of facts and use an objective reporting style.

Documents required for ongoing or anticipated internal enquiries or official investigations must never be destroyed, removed or altered.

Product safety, occupational safety and environmental protection

We demand the highest standards of quality and safety for our products and services. We monitor the quality of our products on the market and help customers avoid potential hazards.

We make sure the working environment is safe. Safety regulations must be strictly followed and checked for their effectiveness. Any non-compliance is to be reported and rectified immediately.

We work economically with natural resources and design our products the same way (in keeping with our “engineering a better life” company philosophy). “engineering a better life” means sustainability and digitalization go hand in hand at ebm‑papst. ebm‑papst stands for green and intelligent production, products and sustainable use of resources and for intelligent control and networking of fans, drives and systems. This makes applications more powerful and processes more efficient.

Avoidance of Conflicts of Interest

We make a clear distinction between business and private interests. Any sideline activities require a prior written consent of ebm‑papst, whereas at least the respective responsible superior must always approve such activities in writing. This applies in particular to sideline work for any rival companies, customers or suppliers of ebm‑papst or financial involvement in these. Notification should be given if any close family members are involved in such activities or participations.

Working for ebm‑papst should also never be used to gain any private advantage. The placing of orders with business partners for private purposes is to be avoided. Trading partners are not to be given preference for private reasons.

We are Part of a Global Society.

Consequently, respect for other cultures and values is a matter of course for us. We treat other people fairly, openly and with respect. We reject all forms of discrimination. We remain politically neutral in the company.

Corporate Communications

Official statements on behalf of ebm‑papst are only to be made by persons authorized to do so. Statements concerning the Group are to be coordinated with the Corporate Communications department in Mulfingen prior to publication.

This Code of Conduct is Binding for all Members of the ebm‑papst Group.

Our management has particular responsibility to set a good example with regard to the ebm‑papst rules and values set out in this code of conduct. Within their area of responsibility, it is their task to ensure compliance with the code of conduct. It can be substantiated and supplemented by regulations and training sessions on particular topics or for specific countries.

Any questions concerning the code of conduct or correct behaviour can be addressed to immediate superiors, the executive management or the compliance team.

Any violation of the code of conduct will not be tolerated and may lead to consequences under labour law, up to and including dismissal or assertion of claims for damages as well as prosecution by the respective authorities.

Your report can help!
The ebm‑papst incident reporting system

ebm‑papst is committed to responsible corporate governance. Therefore, compliance with laws, regulations and internal policies is of the greatest importance at ebm‑papst. Dealing with weaknesses and errors openly helps in the early identification of necessary steps and measures to avert damage to the reputation and assets of ebm‑papst, its employees and business partners.

The web-based and certified whistleblower system BKMS® Incident Reporting is available to all employees and business partners of the ebm‑papst Group as well as any other person around the clock and regardless of location to report compliance violations of legal requirements and internal organizational rules.

You can submit your report anonymously or by providing your contact information. As we seek open communication, we would like to encourage you to state your name when making a report. In any case, we will treat your information as strictly confidential and take into account the legitimate interests of all parties involved.

You can submit a report here:
Incident Reporting System*: https://www.bkms-system.com/ebmpapst
*Please note that the call of the link may be tracked.
To avoid this, please copy the Internet address and paste it into your browser.

On the homepage you will find information about submitting and handling reports.

For more information on how the whistleblower system works, please visit the homepage of Business Keeper GmbH, Germany.

We would also like to inform you about the external reporting offices provided by the federal government. The central external reporting office of the Federal Office of Justice can be found at BfJ - Hinweisgeberstelle*. In addition, the external reporting office of the Federal Financial Supervisory Authority (to the reporting system )* and the external reporting office of the Bundeskartellamt (to the reporting system)* are also available. A detailed breakdown of the responsibilities of the reporting offices can also be found on the homepage of the Federal Office of Justice.

Complaints Procedure

Further information on ebm‑papst's complaints procedure can be found in the Code of Procedure: 

Contact

We seek personal contact with you!

As an employee of ebm‑papst, your first contact should always be your manager.

As a business partner or stakeholder of ebm‑papst, you can contact your known contact person at any time. 

If you do not have a direct contact person, you can communicate your questions and suggestions to the Compliance Officer at any time. 

Gek Wei Lim

Compliance Officer

Address
10 Changi South Street 2, #01-01/02 , 486596 Singapore

E-mail
gekwei.lim@sg.ebmpapst.com